Whittall - Tax Court of Canada finds that gutting only half the rooms in a house did not qualify as “substantial renovation” for GST/HST purposes

An individual gutted and renovated approximately half of the floor space in his bungalow, and did less substantial renovations to the other half (e.g., merely replacing windows, fixtures and doors, and repairing and painting, but not replacing, the drywall). After reviewing the mildly inconsistent jurisprudence, Bocock J concluded that this did not meet the statutory test of “substantial renovation,” so that the individual was not eligible for the GST/HST new housing rebate.

Neal Armstrong. Summary of Whittall v. The Queen, 2017 TCC 212 under ETA s. 123(1) – substantial renovation.